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Public Comment on Removal of Categorical Eligibility for SNAP Beneficiaries

Prepared by Erin Riker, Esq.

The Center for Elder Law and Justice strongly opposes the proposed federal regulation ending categorical eligibility for recipients of Supplemental Nutrition Assistance Benefits (SNAP, colloquially known as food stamps).  If categorical eligibility programs are ended, millions of needy Americans, including substantial numbers of senior citizens, will lose the benefits that allow them to avoid starvation.  Categorical eligibility allows state and local Departments of Social Services to streamline applications for SNAP so that people who have already been proven to be “needy” can get SNAP benefits without excess government red tape.  Categorical eligibility allows states the freedom to administer SNAP benefits to individuals and families that the states have determined are most in need, instead of relying on rigid federal framework that fails to take into account the unique positions of many states.  Finally, categorical eligibility allows more needy people to receive SNAP, which in turn leads to better health outcomes, less overall healthcare spending, and a more productive society.  The benefits of an adequately-fed population should inspire the government to expand SNAP, not take it away.

Categorical eligibility programs allow states to deem certain individuals “eligible” for SNAP if they are eligible for certain other poverty-related assistance programs administered through the Temporary Assistance to Needy Families (TANF) program.  Although each assistance program may have different income and eligibility requirements, each program under the categorical eligibility umbrella is directly related to poverty.  Receipt of any TANF program benefits means, in practical terms, that an individual or family is not having his/her/their basic needs met without assistance.  If an individual or family qualifies for TANF-administered benefits, that individual or family is poor.  If an individual or family is poor, then that individual or family very likely is also having difficulty meeting their basic nutrition needs without the assistance of SNAP.  Therefore, states are allowed to automatically confer SNAP benefits on these people, who have been previously established to be in need, in order to ensure that they have quick access to sufficient nutrition.  This negates the process of multiple wasteful application processes, all of which would have the same outcome – that the individual or family applying needs assistance from our government in meeting their basic needs.

Categorical eligibility also allows states and local DSS offices to tailor their SNAP programs to those who need SNAP benefits most in their areas.  TANF-funded programs are administered by states individually, and can vary in the types of benefits offered by each state.  This has historically given the states the freedom to provide benefits to those residents who need them most, taking into account the vast socioeconomic differences that the many states can have.  The types of benefits needed by the working poor and immigrant populations in Los Angeles and El Paso are not the same as the types of benefits needed by senior citizens in rural states.  State governments have used this flexibility to tailor government benefits to the needs of their residents, to ensure that TANF-funded benefits are given to the residents of each state that need them most.  By extension, SNAP benefits given through categorical eligibility are also given by the states to those who need them most.  The proposed rule’s focus on allowing categorical eligibility primarily for non-cash benefits that support work or child care completely eviscerates the ability of states with large senior citizen populations (who may not be able to work and may no longer be caring for children) to make sure their seniors are adequately fed trough SNAP benefits.

It is true that categorical eligibility allows more individuals to receive SNAP.  However, as stated above, the individuals receiving SNAP are needy, and could not afford proper nutrition without it.  Hunger is more than just a personal struggle – it is a national health issue.  Inadequate nutrition costs our nation an average of $130.5 billion a year in increased healthcare costs, and every dollar that is spent on feeding an otherwise-food-insecure person saves our nation $50 in Medicaid-related expenses. (Source: The Alliance to End Hunger, http://alliancetoendhunger.org).  SNAP benefits have a positive effect on local economies, generating an average of $1.79 in economic activities for every $1 spent on SNAP. (Source: Economic Research Service, US Department of Agriculture, https://www.ers.usda.gov/topics/food-nutrition-assistance/supplemental-nutrition-assistance-program-snap/economic-linkages/).  In fact, in 2015, SNAP benefits lifted an estimated 4.6 million Americans out of poverty, allowing them to fully contribute their talents and resources to making our country great.  (Source: US Census Bureau’s Supplemental Poverty Measure, accessed through Food Research & Action Center, https://frac.org/programs/supplemental-nutrition-assistance-program-snap/positive-effect-snap-benefits-participants-communities).  The myriad benefits to our nation of a program such as SNAP, which ensures that our population has adequate nutrition, should be reason to expand SNAP eligibility nationwide, not restrict it.

For these reasons, the proposed changes to the categorical eligibility SNAP regulations should be abandoned.  These changes will result in increased wasteful government spending on redundant eligibility screenings, handcuff states’ abilities to distribute benefits to the members of their population who need them most, and will cause overall damage to our economy by hampering economic growth and causing healthcare expenses to rise.  Categorical eligibility is a critical element of SNAP benefit qualification, and should be used to expand SNAP access rather than to take it away.

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